Policy statement 18/26
PRA Policy Statement PS18/26 finalises a package of **post‑implementation amendments to Solvency UK reporting and disclosure** and **targeted fixes to the Own Funds framework**, aligned to apply via a single taxonomy update for year‑end 2026 reporting. This matters because insurance compliance teams must adjust regulatory reporting, disclosure processes, and Own Funds permission practices to the updated PRA Rulebook, templates and expectations, including new data requirements for third‑country branches and removal of certain permission requirements.
What Changed
- - The PRA finalises amendments to the Reporting Part of the PRA Rulebook to implement post‑implementation clarifications, consistency improvements and data quality enhancements to Solvency UK...
- Reporting and disclosure templates and instructions are amended (including XBRL taxonomy changes) to reflect the refined Solvency UK reporting framework and consequential changes from the Own Funds...
- The PRA confirms transfer of the Matching Adjustment Asset and Liability Information Return (MALIR) templates from Excel to XBRL submission format, to be incorporated into the single insurance...
- The PRA updates Supervisory Statement 7/18 – Solvency II: Matching adjustment, including changes to the Matching Adjustment supplementary information form under Insurance rule permissions and...
- The PRA introduces a new collection of projected Financial Services Compensation Scheme (FSCS) liabilities data from third‑country branch undertakings to support enhanced branch supervision.
Suggested Considerations
- Review and map existing Solvency UK reporting processes, systems and controls against the amended Reporting Part of the PRA Rulebook and updated templates and instructions to identify required changes for year‑end 2026.
- Engage with finance, risk and actuarial functions to implement the new XBRL‑based MALIR submission process, including testing data extraction, validation and filing workflows aligned to the updated insurance taxonomy.
- Update internal Own Funds policies, classification procedures and governance documentation to reflect removal of specified permission requirements and the amended Own Funds Part and Group Supervision Part of the PRA Rulebook.
- Reconfigure regulatory reporting infrastructure and vendor solutions to adopt the single updated PRA insurance XBRL taxonomy, ensuring all Solvency UK quantitative reporting templates and narrative disclosures are correctly mapped and validated.
- For third‑country branch undertakings, design and implement processes to calculate and report projected FSCS liabilities data in line with PRA expectations, including data sourcing, modelling assumptions and internal review controls.
Key Dates
– Solvency UK reporting and disclosure reforms (phase 2) come into effect for reporting and disclosure reference dates on or after 31 December 2024, including the new Bank of England insurance XBRL taxonomy and removal of the Regular Supervisory Report requirement
– Implementation of PS18/26 reporting and disclosure changes and Own Funds consequential reporting via a **single updated insurance taxonomy**, covering all amended templates, instructions, MALIR XBRL submissions and new FSCS projected liabilities data for third‑country branches
– Liquidity reporting requirements for UK Solvency UK insurers with large derivatives and securities financing transaction exposures come into force, requiring firms above specified thresholds to commence new liquidity reporting
– Revocation of certain Solvency UK Modifications by Consent (including the Reporting MbC) becomes effective; affected third‑country branches meeting premium or provisions thresholds must submit the full branch reporting suite
Compliance Impact
Non‑compliance with the updated reporting, disclosure and Own Funds requirements may result in supervisory findings, requests for remediation, potential use of PRA powers, and could affect the reliability of Solvency Capital Requirement, Own Funds and liquidity assessments. Given the alignment of multiple reforms into a single year‑end 2026 taxonomy update, control failures could have multi‑template, group‑wide impact on regulatory submissions.
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Insurance
Policy statement 16/26
PRA Policy Statement PS16/26 finalises rule changes across multiple CRR-related parts of the PRA Rulebook and Pillar 2 materials to align UK prudential rules with HM Treasury’s new Overseas Prudential Requirements Regime (OPRR), effective 1 January 2027. The changes are primarily technical and clarificatory but have direct implications for how UK banks and PRA-designated investment firms treat and report overseas exposures, including institutions, public sector entities, covered bonds, and large exposures, once CRR equivalence provisions are replaced by the OPRR.
What Changed
- - The PRA Rulebook is amended across core CRR Parts (including Glossary, Credit Risk – General Provisions, Standardised Approach, IRB, Credit Risk Mitigation, Securitisation, Counterparty Credit...
- Definitions of key exposure classes (such as “institution”, “credit institution”, “designated investment firm”, “central government”, “central bank”, “regional government”, “local authority”, “public...
- Under the Standardised Approach to credit risk, the treatment of exposures to overseas credit institutions and designated investment firms is aligned to OPRR designations so that favourable...
- The PRA restates and preserves the 100% risk-weight requirement for exposures to overseas public sector entities (PSEs) in non-designated (non‑equivalent) jurisdictions, maintaining alignment with...
- Large Exposures rules are amended so that exposures to overseas credit institutions and investment firms qualify as “institution” exposures only where HM Treasury has determined the jurisdiction’s...
Suggested Considerations
- Review and update internal capital models and Standardised Approach calculations for credit risk to ensure the classification and risk‑weighting of overseas exposures reflect the new OPRR‑linked definitions (e.g. treatment as “institutions” versus “corporates”) from 01 January 2027.
- Update ICAAP methodologies, risk appetite statements, and SREP documentation (including for SDDTs) to reflect the continued 100% risk weight for overseas public sector entities in non‑designated jurisdictions and any changes to the treatment of overseas covered bonds, institutions, and exchanges.
- Amend Pillar 2 reporting processes and templates, including FSA076 Pillar 2 Credit Risk Standardised Approach returns, to align data capture and reporting with the revised definitions, risk weights, and categorisation of overseas exposures under the PRA’s updated Rulebook and Statements of Policy.
Key Dates
- PRA publishes PS16/26, confirming final rule changes to accommodate the OPRR and indicating that final rules have been made on the understanding that the OPRR statutory instrument will be made and in force prior to 1 January 2027
- HM Treasury is expected to make the OPRR statutory instrument, with the PRA indicating it will amend or revoke its final rules if the instrument is amended prior to being made or is not made
- HM Treasury lays before Parliament the Overseas Prudential Requirements Regime (Credit Institutions and Investment Firms) Regulations 2026, which will replace relevant UK CRR equivalence provisions as the statutory OPRR framework
- The Overseas Prudential Requirements Regime (Credit Institutions and Investment Firms) Regulations 2026 come into force and the PRA’s new rules under PS16/26 take effect, coinciding with the PRA’s broader implementation of the Basel 3.1 standards; from this date, UK CRR equivalence provisions are revoked and replaced by the OPRR framework and associated PRA Rulebook changes
Compliance Impact
Non-compliance could result in mis-stated risk-weighted assets, incorrect large exposure reporting, and flawed ICAAP submissions, exposing firms to supervisory findings, remediation requirements, and potential capital add-ons. Given the changes apply at the core of credit risk, large exposures, and Pillar 2 frameworks, failure to implement them properly may materially affect firms’ regulatory capital ratios and their ability to demonstrate robust prudential management.
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BankBroker Dealer
No description available.
Asset ManagerBroker DealerHedge Fund The Bank of England (the Bank), the Prudential Regulation Authority (PRA) and the FCA will start overseeing the first critical third parties (CTPs) on Monday 13 July 2026, following designation by the Treasury. CTPs are technology and other service providers whose services underpin the UK financial system. Today, the Treasury has announced its first designations of 4 global cloud services and technology providers: Amazon Web Services EMEA SARL, Google Cloud EMEA Limited, Microsoft Ireland Ope...
The Bank of England, PRA and FCA will begin **direct, joint oversight of the first designated Critical Third Parties (CTPs) from 13 July 2026**, covering four major cloud and technology providers whose services underpin UK financial markets. This materially changes the operational resilience landscape: while regulated firms remain fully responsible for their own outsourcing and third‑party risk management, critical dependencies on AWS, Google Cloud, Microsoft and Oracle will now sit within a separate supervisory regime focused on system‑level resilience and incident management.
What Changed
- - A new CTP oversight regime becomes operational on 13 July 2026, under which the Bank of England, PRA and FCA will jointly supervise certain technology and service providers whose failure could...
- HM Treasury has made the first formal CTP designations: Amazon Web Services EMEA SARL, Google Cloud EMEA Limited, Microsoft Ireland Operations Ltd and Oracle Corporation UK Limited.
- Designated CTPs must identify and manage risks to their critical services effectively, including governance, risk management and operational resilience arrangements specifically focused on services...
- CTPs are required to maintain open, timely communication with regulators and with firms that rely on them, particularly during major incidents, implying strengthened incident reporting,...
- The three regulators will jointly oversee CTPs under a proportionate regime focused on resilience of “critical services”, including assessing and mitigating system‑level risks and reducing the risk...
Suggested Considerations
- Review and update the firm’s operational resilience framework, including impact tolerances and scenario testing, to explicitly incorporate systemic risk arising from reliance on the designated CTPs and potential correlated failures affecting multiple services or regions.
- Re‑assess outsourcing and third‑party risk management policies to ensure they clearly distinguish between obligations placed on regulated firms and those placed directly on CTPs, while maintaining robust due diligence, ongoing monitoring and exit strategies for all CTP‑hosted services.
- Engage with designated CTPs (through account management, risk and security channels) to understand their approach to compliance with the CTP regime, including incident reporting arrangements, resilience testing, communication protocols and any new assurance artifacts they plan to provide.
- Update board and senior management reporting so that reliance on designated CTPs, associated systemic risk and regulatory developments under the CTP regime are regularly monitored and discussed at appropriate governance forums (e.g. risk committee, operational resilience committee).
- Review major incident management and crisis communication playbooks to ensure they include specific escalation paths, contact points and joint incident handling procedures with designated CTPs and relevant regulators.
Key Dates
- UK regulators publish final policy and supervisory materials setting out the CTP oversight regime, including Fundamental Rules and operational risk and resilience requirements
- CTP rules and oversight regime take legal effect, but only apply once a provider is designated as a CTP
- Regulations for CTP oversight come into effect for the first designated CTPs; Bank of England, PRA and FCA formally start supervising AWS EMEA, Google Cloud EMEA, Microsoft Ireland Operations and Oracle UK as CTPs
Compliance Impact
Non‑compliance primarily affects regulated firms through weaknesses in operational resilience and third‑party risk management, rather than direct CTP rule breaches, but could result in supervisory findings, remediation programmes, restrictions on business growth and, in serious cases, enforcement action. For designated CTPs, failure to meet the regime’s requirements may trigger direct regulatory intervention, including directions on how services are provided, which can materially impact firms that rely on those services.
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BankBroker DealerPayment Provider ESMA publishes first market capitalisation data for EU Member States 10 July 2026 Market data The European Securities and Markets Authority (ESMA), the EU’s financial markets regulator and supervisor, has published today the annual market capitalisation and market capitalisation ratios of EU Member States for the reference years 2024 and 2025. This publication marks the first implementation of ESMA’s mandate under the FASTER Directive, under which ESMA developed technical standards on the cal...
ESMA’s 10 July 2026 publication is the first operational use of the FASTER Directive framework requiring annual disclosure of each Member State’s market capitalisation and market capitalisation ratio. For compliance teams, the key issue is not the data release itself but the downstream impact: Member States above the **1.5% threshold for four consecutive years** may fall within special withholding tax relief rules, affecting tax-processing, documentation, and eligibility assessments across the market.
What Changed
- - ESMA has started publishing annual market capitalisation figures and market capitalisation ratios for each EU Member State under its FASTER Directive mandate.
- The published figures are based on a harmonised methodology developed by ESMA in technical standards, using transaction data reported under MiFIR.
- Market capitalisation is calculated from shares admitted to trading on a regulated market or multilateral trading facility, with aggregation at the level of the issuer’s legal address in the relevant...
- The market capitalisation ratio is calculated as the Member State’s market capitalisation divided by the total market capitalisation of all Member States on the same date, expressed as a percentage.
- Member States whose market size exceeds 1.5% of total EU market capitalisation for four consecutive years are subject to specific withholding tax relief-related requirements.
Suggested Considerations
- Compliance teams should map whether any serviced Member State may approach or exceed the 1.5% threshold over a rolling four-year period and flag jurisdictions that could trigger special withholding tax relief consequences.
- Tax operations teams should align withholding tax relief workflows with the ESMA-published ratios so that jurisdictional eligibility assessments use the current official figures.
- Data and controls teams should document the calculation source, methodology, and reconciliation process for any internal use of ESMA market capitalisation data.
- Investment firms and intermediaries should review client-facing tax-relief processes to ensure they can respond to changes in Member State status under FASTER.
- Market-data and regulatory-reporting teams should prepare for annual updates by building a recurring review process around each ESMA publication cycle.
Key Dates
- The FASTER Directive was published in the Official Journal of the EU, establishing the legal basis for ESMA’s market capitalisation mandate
- ESMA published a consultation paper on the draft RTS methodology for calculating market capitalisation and the market capitalisation ratio
- The consultation period for ESMA’s draft RTS methodology closed
- ESMA was expected to finalise the RTS and submit them to the European Commission
- The European Commission issued a final document referring to the FASTER framework and its threshold mechanics
Compliance Impact
The immediate regulatory impact is medium to high because the publication does not itself impose new firm-level filing duties, but it informs a threshold-based regime that can materially affect withholding tax relief eligibility and operational processing. Non-compliance risk rises where firms fail to update jurisdictional tax workflows, leading to incorrect relief treatment, delays, or disputes with counterparties and tax authorities.
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All FirmsBankBroker Dealer The Upper Tribunal has made an order suspending parts of the scheme. We set out what the partial suspension means for firms and consumers. The Upper Tribunal has confirmed it will hear the legal challenges to our motor finance scheme on 14 to 18 December 2026 or 16 to 26 February 2027. The final dates depend on whether any of those involved in the case apply for further expert opinion or disclosure of information, and whether any such application is successful.The Tribunal has also made an or...
The Upper Tribunal has ordered a **partial suspension** of the FCA’s motor finance consumer redress scheme rules, primarily pausing redress calculation, payment and compensation communications while legal challenges are heard. Compliance teams at motor finance lenders and brokers must now operate under a split regime: preparatory and data‑gathering obligations under PS26/3 remain in force, but scheme‑timetable obligations on paying and notifying compensation are paused until the Tribunal process concludes.
What Changed
- - Parts of the FCA motor finance consumer redress scheme under PS26/3 are formally suspended by order of the Upper Tribunal, on terms agreed between the FCA and four challengers (Consumer...
- During the suspension, firms are not required to calculate redress, pay compensation, or send communications about compensation owed under the scheme according to the original timetable.
- All non‑suspended rules remain fully applicable, including duties to identify in‑scope complaints and agreements, gather commission and disclosure data (including from brokers), and maintain records.
- Lenders must continue to identify relevant complaints and agreements falling within scheme scope (motor finance agreements between 2007 and 2024 with potentially unfair commission arrangements).
- Firms must continue to gather data on commission arrangements and disclosure practices, including obtaining information from brokers and confirming where such information is not held.
Suggested Considerations
- Identify and maintain a complete inventory of motor finance complaints and agreements that fall within the scheme scope (regulated motor finance with relevant commission arrangements between April 2007 and 2024).
- Continue to gather, centralise and validate data on commission structures, commission levels, and disclosure practices for all in‑scope agreements, including by issuing targeted information requests to brokers and dealers.
- Implement internal workflows to ensure brokers respond to lenders’ information requests within one month, or formally confirm where requested documents or data are not held.
- Review and classify complaints to determine which consumers are not owed compensation under the scheme, including cases outside scope and those lacking discretionary, high or tied commission arrangements, and prepare appropriate communications.
- Assess complaints for time‑bar issues and apply the scheme’s limitation and out‑of‑time principles consistently, documenting rationale for any reliance on time‑bar to decline redress.
Key Dates
– Consultation on the proposed motor finance redress scheme closes (CP25/27), feeding into the final PS26/3 rules
– Firms must start sending final responses to any motor leasing complaint in line with normal complaint‑handling rules (outside the scheme‑specific pause)
– FCA confirms its motor finance compensation scheme has been legally challenged, triggering the Upper Tribunal process
– FCA lifts the general pause on handling certain motor finance complaints, returning many complaints to standard DISP timeframes, alongside the emerging scheme
– Original end of the implementation period for loans taken out from 1 April 2014 under PS26/3 (now effectively paused for redress calculation/payment/communications)
Compliance Impact
Non‑compliance with the remaining live scheme rules and complaint‑handling requirements exposes firms to supervisory intervention, possible enforcement action and heightened FOS risk, even during the suspension. Failures in data gathering, record‑keeping or timely communications to non‑compensated complainants will also materially increase operational, litigation and reputational risk once the Tribunal clarifies the scheme’s future.
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The Retail Payments Infrastructure Board (RPIB), led by the Bank of England, recently published a consultation on the future retail payments infrastructure.To support the consultation, the Payment Vision Delivery Committee (PVDC) which comprises representatives of HM Treasury, the FCA, Bank of England and the PSR, has published further context to support stakeholders' reading of the consultation. It covers issues such as how the commercial model for the infrastructure should work and how the ...
The FCA statement confirms that the Retail Payments Infrastructure Board (RPIB), led by the Bank of England, has launched a major consultation on the **design of the future UK retail payments infrastructure**, supported by contextual material from the Payments Vision Delivery Committee (PVDC). This marks a key implementation step in the UK National Payments Vision, with significant implications for commercial models, access, consumer protection and financial crime controls across all retail payment schemes and providers.
What Changed
- - A new governance and delivery model for UK retail payments infrastructure is being operationalised, with strategy set by the PVDC, design work led by the RPIB, and implementation by a new...
- The RPIB has launched a formal consultation on the design of the future retail payments infrastructure, seeking views on payment journeys, key design choices and priorities.
- The PVDC has published additional context to support stakeholders’ reading of the consultation, including expectations for the commercial model, consumer protection outcomes and financial crime...
- Responsibilities across the ecosystem are being reset, with clearer roles for public authorities (HM Treasury, Bank of England, FCA, PSR), Pay.UK, and industry participants in designing and...
- Next‑generation infrastructure is expected to support account‑to‑account payments at point of sale, enhanced cross‑border payments, and interoperability with new forms of digital money (including...
Suggested Considerations
- Assess and document your firm’s current and projected use of UK retail interbank payments (including Faster Payments, account‑to‑account, and cross‑border flows) to inform your response to the RPIB consultation.
- Prepare and submit a coordinated consultation response to the RPIB by 11 September 2026, covering your views on payment journeys, design choices, consumer protection needs and financial crime controls.
- Review your firm’s commercial and pricing models for interbank payments to understand how potential changes to the future infrastructure’s commercial model could affect revenue, costs and access.
- Map dependencies between your operational resilience framework and the existing UK retail payments infrastructure, and identify key risks and mitigants under a transition to the next‑generation infrastructure.
- Engage with industry bodies, Pay.UK and relevant trade associations to align positions on access, interoperability, fraud management, and technical standards for next‑generation retail payments.
Key Dates
(TBD) - PVDC expected to publish its detailed **strategy for retail payments infrastructure**, setting key priorities for next‑generation infrastructure and aligning with the National Payments Vision
(already in train) - HM Treasury consultation on retained EU payments law and FCA engagement paper (Payments Forward Plan context; relevant for alignment with infrastructure changes)
- Retail Payments Infrastructure Board consultation on the design of the Future Retail Payments Infrastructure is launched
- Deadline for submission of responses to the RPIB consultation on the future retail payments infrastructure
Compliance Impact
Non‑engagement with this consultation and subsequent strategy may leave firms exposed to future infrastructure, access and fraud‑control requirements that they have not planned or invested for, with potential operational disruption, competitive disadvantage and heightened regulatory scrutiny. In the medium term, failure to adapt to the new infrastructure model could impair compliance with payment systems regulation, operational resilience expectations and Consumer Duty outcomes.
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Payment ProviderBankFintech The Bank of England and the FCA have published a joint approach setting out how they and where relevant other authorities will work together to regulate systemic stablecoin issuers in the UK.It explains how responsibilities will be split between the authorities, and how UK stablecoin issuers may move from FCA supervision to joint regulation once recognised as systemic by HM Treasury.The approach aims to provide clarity and predictability for firms as the market develops.Read the paper
The FCA and Bank of England have set out a joint supervisory model for **systemic stablecoin issuers**, clarifying how firms will move from FCA-only oversight to joint regulation once HM Treasury designates them as systemic. This matters because UK‑based and non‑UK stablecoin issuers used for payments will face distinct prudential, conduct and structural requirements depending on whether they are non‑systemic (FCA only) or systemic (Bank of England plus FCA), with a managed transition between regimes.
What Changed
- - UK stablecoin issuance will be subject to a dual regulatory regime: non‑systemic stablecoins will be supervised solely by the FCA, while systemic stablecoins used for payments will be jointly...
- Issuing a qualifying sterling‑denominated stablecoin in the UK will become a regulated activity, requiring FCA authorisation for non‑bank issuers and bringing them within the FCA’s prudential,...
- HM Treasury will apply statutory systemic tests under the Banking Act (e.g. scale, interconnectedness, substitutability, impact on confidence in sterling) to decide whether a stablecoin payment...
- Once recognised as systemic, stablecoin issuers and systemic payment system providers will fall under the Bank of England’s remit under the Banking Act 2009, including powers to obtain information,...
- Systemic sterling‑denominated stablecoin issuers will be required to maintain backing reserves equal to all outstanding coins, with backing assets held on statutory trust in the UK and ring‑fenced...
Suggested Considerations
- Map all existing and planned sterling‑denominated stablecoin products against the UK’s systemic and non‑systemic regimes and assess whether their intended use in UK payments could trigger HM Treasury systemic recognition.
- Initiate or update FCA authorisation applications for stablecoin issuance and cryptoasset custody activities, ensuring business models, governance and safeguarding arrangements align with CP25/14 and the forthcoming stablecoin regime.
- Design and implement reserve‑management frameworks capable of maintaining backing assets equal to outstanding coins, in the proposed 70/30 mix between short‑term UK government debt and Bank of England deposits, with appropriate stress testing and liquidity risk oversight.
- Establish statutory trust and segregation structures for backing assets and liquid‑asset reserves, including appointing UK‑authorised third‑party custodians and aligning documentation with FCA client‑asset‑style protections and coinholder proprietary claims.
- Develop capital planning processes and ICAAP‑style assessments to meet the Bank of England’s requirements for capital against general business risk and dedicated reserves for financial risk and wind‑down costs.
Key Dates
- Bank of England consultation paper issued on the proposed regulatory framework for sterling‑denominated systemic stablecoins and systemic payment system operators
- Bank of England intends to finalise the Code of Practice and supporting materials by the end of 2026, confirming the prudential and structural regime for systemic stablecoins
- UK introduces new regulatory authorisation requirements for stablecoin issuers, including FCA authorisation for qualifying issuance and custody activities
- Consultation period closes for the Bank of England’s systemic stablecoin regime proposals
- Bank of England publishes its policy statement and draft Code of Practice for systemic stablecoin issuers, setting out detailed prudential and backing‑asset rules and confirming joint work with the FCA on an end‑to‑end regime
Compliance Impact
Non‑compliance with the emerging stablecoin regime may result in refusal of authorisation, enforcement directions, restrictions on issuance volumes, and potential wind‑down of stablecoin products, with significant balance‑sheet, reputational and operational consequences. Systemic issuers face heightened supervisory scrutiny and Banking Act enforcement powers, making early alignment with prudential, safeguarding and governance expectations critical.
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FintechCrypto ExchangeBank Drax Group PLC (Drax) has announced the FCA has closed its investigation into the company.We undertook an extensive investigation following concerns raised regarding disclosures to the market about the sustainability of Drax’s Canadian biomass. We did not find evidence that justified any further action.Thousands of pages of complex material were reviewed as part of the investigation, and individuals from the company interviewed. Our focus was on areas within our remit, specifically whether Dr...
The FCA concluded its investigation into Drax without taking action after an extensive review of “thousands of pages” and interviews with company personnel, focused on whether Drax’s annual reports and accounts from 2021 to 2023 contained misleading statements or material omissions about biomass sustainability. This matters because it shows the FCA continues to scrutinize **listed-company disclosures** on ESG and sustainability claims, especially where prior regulatory findings or public controversies may indicate potential market disclosure risk.
What Changed
- - The FCA has closed its investigation into Drax Group PLC and will take no further action.
- The FCA confirmed that it reviewed whether Drax’s 2021, 2022 and 2023 annual reports and accounts contained misleading statements or omitted important information for investors.
- The FCA stated that its focus was limited to matters within its remit as a listed-company regulator, not a general review of Drax’s broader operations.
- The FCA’s approach confirms that sustainability-related market disclosures can be assessed under listed-company continuing disclosure obligations where they affect investor understanding.
- The FCA indicated that it will close cases where evidence does not support proportionate action, even after a substantial investigation.
Suggested Considerations
- Review annual report drafting controls to ensure sustainability statements are supported by underlying source data and governance evidence before publication.
- Map ESG and environmental claims to the exact disclosure obligations that apply to listed issuers, including continuing disclosure and annual report requirements.
- Test whether statements about biomass sourcing, carbon impact, or sustainability performance could be viewed as misleading without full context or qualifying information.
- Maintain a defensible audit trail showing how disputed environmental data, third-party evidence, and management judgments were validated before disclosure.
- Escalate any controversy involving regulator findings, whistleblower allegations, or media investigations to disclosure committees and legal counsel early in the reporting cycle.
Key Dates
- Period covered by the FCA’s review of Drax’s annual reports and accounts
- Period covered by the FCA’s review of Drax’s annual reports and accounts
- Period covered by the FCA’s review of Drax’s annual reports and accounts
- Ofgem announced conclusions on Drax’s reporting of biomass profiling data, which later formed the background to the FCA’s interest
- The FCA closed the investigation and confirmed that no further action would be taken
Compliance Impact
The practical severity is moderate to high for listed issuers because the FCA’s review shows it will investigate potentially misleading sustainability disclosures and expects accurate, investor-relevant reporting. Non-compliance can lead to enforcement exposure, remediation costs, reputational damage, and intensified scrutiny of future ESG statements even where no action is ultimately taken.
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All Firms
The FCAhasstartedcivil proceedings against Mr Neil Woodford andW4.0.The FCAallegesthat Mr Woodford and W4.0 are providing regulated investment advice and making financial promotions through the subscription-based platform, www.w4pz.com, without authorisation.In the FCA’sview, the activitybreachessections 19 and 21 of the Financial Services and Markets Act 2000 (FSMA).The FCA is seekingan injunction against Mr Woodford and W4.0 tostop them carrying on the potentiallyunlawfulactivities.W4.0 is ...
The FCA has commenced civil proceedings against Neil Woodford and W4.0 (W Four Point Zero FZE LLC, UAE‑registered), alleging they provided regulated investment advice and made financial promotions to UK consumers via subscription platform www.w4pz.com without FCA authorisation, in breach of sections 19 and 21 FSMA 2000. The case underscores that overseas structures, subscription “community” models, and model‑portfolio or strategy platforms aimed at UK users will be treated as carrying on UK‑regulated activities and financial promotions if they effectively target or advise UK investors.
What Changed
- - The FCA has publicly confirmed that providing model portfolios, strategies or investment recommendations via a subscription website can constitute regulated investment advice and financial...
- The FCA is treating digital “community platforms” and strategy‑copying services as potentially regulated activities, not merely education or general commentary, where users are expected to implement...
- The FCA has explicitly framed such activity as breaching the general prohibition in section 19 FSMA (carrying on a regulated activity in the UK without authorisation or exemption) when done without...
- The FCA has explicitly framed such online communications as breaching the financial promotion restriction in section 21 FSMA where no authorised firm approves or issues the promotions.
- The regulator has commenced civil proceedings and is actively seeking an injunction from the court to force the immediate cessation of the allegedly unlawful advice and promotion activities.
Suggested Considerations
- Conduct an immediate perimeter review of all digital, subscription‑based, model‑portfolio, and strategy‑distribution offerings to determine whether they constitute regulated investment advice or arranging, requiring FCA permission.
- Review all online content, marketing materials, newsletters, videos, and “community” communications to identify any that could amount to a financial promotion to UK consumers and ensure they are issued or approved by an authorised firm under section 21 FSMA, or fall clearly within an exemption.
- Update internal policies and product‑governance frameworks for research, commentary, and model portfolios so that any service intended to be implemented by clients is classified and treated as a regulated activity where relevant.
- For groups using non‑UK entities to host platforms or provide content, perform a jurisdictional analysis and document how UK‑facing activities are controlled, authorised, or carved out to avoid a breach of FSMA sections 19 and 21.
- Implement or strengthen pre‑clearance procedures for senior individuals (particularly previously sanctioned or restricted persons) seeking to launch new client‑facing propositions, ensuring that any new business line is assessed for authorisation and promotion requirements before launch.
Compliance Impact
Non‑compliance exposes firms and individuals to civil proceedings, injunctive relief, financial penalties, and potentially prohibition orders, alongside significant reputational damage. The case demonstrates the FCA’s willingness to litigate perimeter breaches for digital and overseas platforms, making this a high‑risk area for firms operating at or near the border of regulated advice and promotions.
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Asset ManagerWealth ManagerFintech The U.S. Securities and Exchange Commission established joint data standards under the Financial Data Transparency Act of 2022. The final rule establishes technical standards for data submitted to certain financial regulatory agencies. Eight additional…
The SEC has adopted **joint data standards** under the Financial Data Transparency Act of 2022 (FDTA) to govern how data is formatted and submitted to specified U.S. financial regulators, including the SEC. This materially raises the bar on data structure, tagging, and interoperability for regulatory reporting and disclosures, requiring firms to shift from document-centric to **machine‑readable, standardized data** across multiple reporting regimes.
What Changed
- - The SEC, jointly with seven other U.S. financial regulators, has established mandatory technical data standards for information submitted to those agencies pursuant to the Financial Data...
- The joint standards apply to regulatory data collections within each participating agency’s remit (e.g., SEC filings and reports, certain prudential and market data submissions), and are intended to...
- The rule requires use of structured, non‑proprietary, machine‑readable formats (such as XML, JSON, XBRL, or similar open standards) where data is collected electronically, moving away from...
- The standards require use of public, non‑exclusive data dictionaries and taxonomies, so that data elements (e.g., fields, metrics, identifiers) are consistently defined and tagged across different...
- The rule embeds interoperability requirements, so that the same data element (for example, a LEI, CUSIP, counterparty ID, asset class, or exposure type) is reported using harmonized definitions and...
Suggested Considerations
- Conduct a comprehensive mapping of all current and upcoming regulatory data submissions to the SEC and other FDTA‑covered agencies to identify which reports are likely to be brought under the joint data standards.
- Review and update data governance frameworks so that key data elements (counterparty identifiers, instrument identifiers, balances, exposures, classifications) are uniquely defined, consistently sourced, and traceable across internal systems in alignment with anticipated joint taxonomies.
- Assess existing regulatory reporting systems and vendor solutions (including XBRL tools, data warehouses, and filing platforms) and develop an upgrade plan to support the new machine‑readable, standardized formats and schemas.
- Establish an internal FDTA/joint data standards implementation program, with clear ownership (e.g., finance, regulatory reporting, data management, IT) and a cross‑functional steering committee to oversee design, testing, and rollout.
- Engage with technology, regtech, and data vendors to confirm their timelines for supporting the new SEC and cross‑agency standards and to obtain updated taxonomies, schemas, and validation rules as soon as they are published.
Key Dates
– SEC press release date and effective date of the joint data standards rule (exact calendar date to be taken from the final rule and press release)
– SEC and other participating agencies publish technical specifications, schemas, and implementation guides for specific forms and data collections that will transition to the joint data standards
– Phased compliance dates for particular reporting forms and regimes as each agency completes its implementation plans under the FDTA; individual forms will have distinct first‑applicable reporting periods and transition windows
Compliance Impact
The impact is high, because the rule drives structural changes to how regulatory data is formatted, governed, and submitted, with material systems and process implications across multiple reporting regimes. Non‑compliance may result in rejected filings, late‑filing violations, enforcement risk, and increased scrutiny over the accuracy and reliability of reported data.
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original SEC source
before acting. Full disclaimer.
BankAsset ManagerBroker Dealer We set out next steps on issuing new rules and guidance on Money Market Funds (MMFs), following Government plans to replace the current rules. On 15 May, the Government set out its expectation that it will lay legislation that will replace the UK Money Market Funds Regulation. Read the Government statement.Money Market Funds (MMFs) play an important role in the financial system. MMFs are widely used for cash management and provide an alternative or complement to bank deposits for a broad rang...
The FCA has confirmed its *updated approach* to UK money market fund (MMF) reforms, signalling that most detailed MMF requirements will move from retained EU law into FCA rules and guidance, with a new overarching “adequate resilience” liquidity rule and revised expectations for weekly liquid assets (WLA). The key compliance implication is a shift from hard, uniform liquidity minima to a combination of existing regulatory minima plus *supervisory expectations* of 40% WLA for stable NAV MMFs and 20% WLA for variable NAV MMFs, alongside confirmation that “delinking” and enhanced KYC measures will proceed.
What Changed
- - The FCA will introduce a new overarching rule requiring that all UK‑domiciled MMFs must hold sufficient liquidity for “adequate resilience”, explicitly linking fund liquidity to financial stability...
- The FCA will retain the current minimum WLA requirements from the existing UK Money Market Fund Regulation (UK MMFR) in its rules, instead of the previously consulted increases to 50% WLA for all...
- The FCA will issue guidance setting out strong supervisory expectations that stable NAV MMFs should hold 40% WLA and variable NAV MMFs should hold 20% WLA to meet the new resilience requirement,...
- The FCA makes clear that falling below the 40%/20% WLA supervisory expectations should only occur to meet redemption requests or due to factors beyond the manager’s control, and should be rare, with...
- The FCA will retain existing minimum daily liquid asset (DLA) requirements from UK MMFR in rules and does not plan to issue new guidance on DLA levels, but expects DLA and WLA together to be...
Suggested Considerations
- Conduct a comprehensive gap analysis comparing current MMF liquidity management frameworks (DLA, WLA, and stress‑testing assumptions) against the forthcoming FCA “adequate resilience” rule and the 40% (stable NAV) / 20% (variable NAV) WLA supervisory expectations.
- Update MMF liquidity policies, board‑approved risk appetites, and internal limits to reflect the new WLA expectations, including documentation of when and how funds may temporarily operate below 40%/20% WLA and the governance required to approve such deviations.
- Implement enhancements to liquidity monitoring and MI reporting so that portfolio managers, risk, and compliance have near‑real‑time visibility of DLA and WLA levels, breaches of internal and supervisory thresholds, and redemption‑driven use of liquidity buffers.
- Review and update fund prospectuses, KIIDs/KIDs, and investor disclosures to ensure that descriptions of MMF liquidity management, the availability of liquidity management tools, and the operation of stable NAV structures are accurate under the new FCA regime.
- Revise and strengthen investor KYC procedures for MMFs to capture concentration risks and potential correlated outflows, including segmentation of investor types, monitoring of large holders, and scenario analysis around key client redemption behaviour.
Key Dates
– FCA publishes CP23/28 “Updating the regime for Money Market Funds,” consulting on higher liquidity minima (15% DLA and 50% WLA), delinking, enhanced KYC, and broader resilience measures
– HM Treasury and the FCA publish the joint policy statement “Reforms to Money Market Fund Regulations,” confirming the Government’s intention to replace the UK MMFR with a new framework and that most MMF requirements will be set in FCA rules and guidance, including higher liquidity expectations
– FCA issues its statement “FCA update on reforms to the UK Money Market Fund Regulation,” setting out updated proposals, including retention of current minimum WLA in rules, the new “adequate resilience” liquidity rule, and supervisory expectations of 40% WLA for stable NAV and 20% WLA for variable NAV MMFs, and indicating that CP23/28 measures such as delinking and enhanced KYC will largely be taken forward
– The UK’s new MMF regime is expected to be in place, subject to Parliamentary approval of the enabling legislation, after which the detailed FCA rules and guidance (including the new resilience rule and WLA expectations) will apply
– HM Treasury will lay the statutory instrument replacing the UK MMFR with the new legislative framework under which FCA rules and guidance for MMFs will be made
Compliance Impact
Non‑compliance with the new FCA MMF rules and supervisory expectations is likely to be treated as a significant prudential and conduct issue, exposing firms to supervisory intervention, potential restrictions on MMF operations, and enforcement action where governance or disclosure failures are identified. Given the explicit financial stability focus of these reforms, regulators can be expected to scrutinise outlier funds and firms that do not align internal practice with the 40%/20% WLA expectations or that cannot evidence robust liquidity and KYC frameworks.
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Asset ManagerHedge FundBank The Bank of England has published a joint review with the FCA on how the Memorandum of Understanding (MoU) for financial market infrastructure (FMI) is working. The Bank of England and the FCA (the authorities) cooperate on the supervision of FMIs.The authorities consulted with FMIs to assess the effectiveness of cooperation between the Bank and FCA over the past 12 months.Following the responses, the authorities have concluded that the arrangements for cooperation remain effective with appro...
The Bank of England and FCA have completed their 2025/26 joint review of the Memorandum of Understanding (MoU) governing cooperation on the supervision of UK financial market infrastructures (FMIs) and have concluded that current arrangements remain effective, well‑coordinated and free from material duplication. For compliance teams at FMIs and connected firms, this confirms regulatory expectations around information‑sharing, supervisory engagement and coordinated oversight by the two authorities, but does not introduce new rules or materially change existing supervisory practice.
What Changed
- - The Bank of England and FCA confirm, following consultation with FMIs over the last 12 months, that the existing MoU framework for supervisory cooperation on financial market infrastructures...
- The authorities explicitly reaffirm their commitment to efficient coordination to enhance the effectiveness of supervision, signalling continued emphasis on timely, accurate and proactive information...
- The statement maintains, rather than revises, the current allocation of responsibilities between the Bank of England (as primary prudential and systemic supervisor for FMIs) and the FCA (as conduct,...
- The authorities confirm the continuation of an annual review process of the MoU, including consultation with supervised FMIs to obtain feedback on how coordination is working in practice, embedding...
- The publication sits alongside the underlying 2025 MoU text (and the broader multi‑regulator MoU framework with FCA, PRA and PSR), reinforcing that FMIs should align their governance, reporting and...
Suggested Considerations
- Confirm internally that your firm’s regulatory engagement framework recognises the Bank of England–FCA MoU and clearly allocates responsibilities for managing relationships with both authorities in line with their respective roles.
- Review and, where necessary, update internal regulatory communications and escalation procedures to ensure that information relevant to both the Bank of England and FCA can be shared consistently, accurately and on a timely basis, in anticipation of coordinated supervisory expectations.
- Prepare to continue providing structured, constructive feedback during the annual MoU review process by maintaining records of supervisory interactions with each authority, including instances of overlap, gaps, or divergent expectations.
- Align incident management, operational resilience and major change approval processes with the expectation that both authorities may need to be informed and coordinated, and verify that notification playbooks and contact trees reflect this dual‑regulator structure.
- For groups operating multiple FMIs or cross‑border infrastructures, map where other regulators rely on the Bank of England/FCA supervisory cooperation (for example, via substituted compliance or recognition regimes) and integrate this into your global regulatory engagement strategy.
Key Dates
– The Bank of England and FCA wrote to CCPs, RIEs and RCSDs to request feedback on the effectiveness of cooperation under the MoU based on firms’ interactions during 2024
– The authorities conducted the annual joint review of the MoU for FMIs, considering the responses received from supervised entities over the preceding 12 months and assessing the effectiveness of coordination and duplication
– The Bank of England and FCA will continue to review the MoU each year, including soliciting feedback from FMIs, to confirm that supervisory cooperation remains effective and to identify potential enhancements
Compliance Impact
Non‑compliance would not typically arise directly from the MoU review outcome itself, but FMIs that fail to align with the coordinated expectations and information‑sharing practices of the Bank and FCA risk fragmented supervisory relationships, increased scrutiny, and potential enforcement where underlying prudential, conduct, or operational resilience requirements are not met. Effective engagement with both regulators remains critical to maintaining authorisation, recognition status and continued operation of systemically important market infrastructure.
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BankBroker DealerAsset Manager amending the regulatory technical standards laid down in Delegated Regulation (EU) 2019/979 as regards updating the list of data necessary for the classification of prospectuses and the list of information that can be incorporated by reference into prospectuses
Commission Delegated Regulation (EU) 2026/395 of 23 February 2026 amends the Prospectus Regulation RTS in Delegated Regulation (EU) 2019/979 to update: (i) the **data set used for ESMA classification and filing of prospectuses** and (ii) the **categories of information that may be incorporated by reference** into a prospectus.
For compliance teams in Luxembourg and across the EU, this means prospectus production, filing templates, and reference documentation frameworks must be revised so that all new prospectuses and supplements meet the updated RTS data and incorporation-by-reference standards under Regulation (EU) 2017/1129.
What Changed
- - The amending Delegated Regulation updates the list of data fields required for the classification of prospectuses under Delegated Regulation (EU) 2019/979, impacting how issuers and their advisors...
- The RTS amendment revises the list of information that can be incorporated by reference into a prospectus, narrowing or clarifying which external documents (e.g.
- Prospectus classification data fields are expected to better align with current ESMA Prospectus Register needs (for example finer product type, offer type, and home/host state metadata), requiring...
- The updated incorporation-by-reference list seeks to ensure that only readily accessible and reliable information may be referenced, which will affect how issuers structure cross‑references to annual...
- National competent authorities, including the CSSF, will apply the revised RTS when reviewing and approving prospectuses and supplements, meaning filings that use outdated data sets or ineligible...
Suggested Considerations
- Map all existing prospectus templates, checklists and workflows against the revised Delegated Regulation (EU) 2019/979 data fields and immediately identify gaps in prospectus classification data and reference documentation.
- Update internal prospectus data dictionaries and metadata schemas so that all new and updated prospectuses capture the full revised list of ESMA classification data required by the amended RTS.
- Review and revise the firm’s incorporation‑by‑reference policy, including standard clauses and cross‑reference tables, to ensure only information categories permitted under the updated RTS are incorporated by reference.
- Reconfigure electronic filing tools and interfaces used for submissions to the CSSF (and other NCAs) so that they generate and transmit the updated RTS data set required for classification and ESMA register purposes.
- Train legal, capital markets, and product teams involved in prospectus drafting on the new RTS requirements, including examples of acceptable and non‑acceptable incorporation‑by‑reference documents.
Key Dates
- Original Delegated Regulation (EU) 2019/979 is adopted, setting the RTS on key financial information, publication and classification of prospectuses, advertisements, supplements and incorporation by reference
- Commission Delegated Regulation (EU) 2026/395 is adopted, amending Delegated Regulation (EU) 2019/979 on the list of data necessary for prospectus classification and the list of information allowed to be incorporated by reference
- CSSF publishes notice of Delegated Regulation (EU) 2026/395, signalling its relevance for Luxembourg‑supervised entities and prospectus approval processes
- The Delegated Regulation will enter into force on the date specified in the Official Journal; in line with standard EU practice, firms should expect application from a specified date shortly after OJ publication and plan prospectus updates accordingly
Compliance Impact
Non‑compliance can lead to prospectus approval delays, rejection of filings, or required resubmissions, which may disrupt issuance timetables and investor communications. Persistent or material breaches may expose firms and issuers to supervisory measures, sanctions, and reputational risk for failing to meet Prospectus Regulation standards.
AI-generated analysis. May contain errors or omissions — verify with the
original CSSF source
before acting. Full disclaimer.
BankBroker DealerAsset Manager
The UK Payments Initiative (UKPI) announcement signals a major step forward for open banking and commercial variable recurring payments (cVRP). The launch of UKPI paves the way for greater payments competition, innovation and economic growth.Read the announcement.The industry-led scheme will give people more choice about how and when they pay for recurring goods and services.We want to see competition between commercial open banking schemes and expect the launch of the first scheme by UKPI to...
The FCA has published a short policy statement signalling regulatory support for the industry‑led **UK Payments Initiative (UKPI)**, an open banking scheme to deliver commercial variable recurring payments (cVRP) and broader payments innovation. For compliance teams, this marks an early but clear indication that the FCA expects firms to prepare for a future **formal regulatory framework for open banking/open finance and commercial schemes**, with consultation to follow once enabling legislation grants the FCA expanded powers by the end of 2026.
What Changed
- - The FCA publicly endorses the launch of the UK Payments Initiative (UKPI) as an industry‑led open banking payments scheme focused on commercial variable recurring payments (cVRP), signalling...
- The statement confirms the FCA wants competition between commercial open banking schemes, indicating a shift from a single mandated model (under PSD2/open banking implementation) towards multiple...
- The FCA signals support for the creation of an independent standards‑setting body for open banking payments, moving standard‑setting away from transitional arrangements towards a more permanent,...
- The FCA announces its intention, subject to future legislation granting new powers, to consult on a long‑term regulatory framework for open banking (and, by extension, commercial open banking schemes...
- The FCA links this announcement to its regulatory roadmap for open finance, confirming that open banking data‑sharing will be extended to broader financial data, providing a strategic direction of...
Suggested Considerations
- Conduct an internal assessment of how your firm currently uses or plans to use open banking and cVRP (e.g., recurring payments, subscription billing, merchant acquiring) and document potential exposure to UKPI or similar schemes.
- Establish or update a regulatory horizon‑scanning process to track: (i) UKPI scheme documentation and rulebooks, (ii) FCA’s forthcoming open finance regulatory roadmap outputs, and (iii) the enabling legislation that will grant the FCA new powers.
- Engage product, legal and compliance teams to map existing recurring payment processes and consumer consent flows against anticipated expectations for open banking cVRP, including clarity of consent, cancellation rights, transparency of variable amounts, and dispute handling.
- Review and, where necessary, update data protection, API security, and customer authentication controls to ensure they can support commercial open banking schemes and more granular data‑sharing under an open finance regime.
- For firms intending to participate in UKPI, proactively review and align internal policies with emerging industry standards and scheme rules, including technical standards, liability allocation, service‑level requirements, and complaints/chargeback processes.
Key Dates
– FCA intends to consult on a **long‑term regulatory framework for open banking** (and related commercial schemes such as UKPI), subject to the granting of new powers in legislation
– UK legislation is expected to give the FCA new powers over open banking/open finance, which is a precondition for FCA consultation on a long‑term framework
Compliance Impact
In the immediate term, compliance impact is medium: no new binding rules are introduced, but the FCA’s direction of travel is clear and requires strategic planning. Over the medium term (to and beyond 2026), failure to anticipate the formal open banking/open finance framework, or to adapt recurring payment practices and controls to emerging standards, is likely to create material conduct, operational and supervisory risk.
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original FCA source
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BankFintechPayment Provider No description available.
The CFTC has implemented a technical enhancement to its electronic Portal system that allows exchanges to submit a single set of product self‑certification documents covering multiple closely related contracts in one consolidated filing. This matters for compliance teams at CFTC‑registered exchanges because it changes the *operational* process for Part 40 product submissions, reduces duplicative documentation, and will require updates to internal procedures, templates, and controls governing self‑certifications.
What Changed
- - The CFTC Portal now supports consolidated product self‑certification submissions, enabling exchanges to file a single set of certification documents that apply to multiple closely related contracts...
- Exchanges are no longer required to upload multiple identical copies of supporting product certification documents when listing several closely related contracts; one shared documentation set can be...
- The enhancement is framed as an administrative/technical change to the filing process; it does not alter substantive legal standards for product self‑certification under the Commodity Exchange Act or...
- The CFTC has issued updated submission instructions on the Portal site specifying how to use the new consolidated filing functionality, including formatting and process guidance.
- Dedicated technical and non‑technical CFTC contacts have been identified (Howard Rosen for system use; Chris Goodman for product submission process questions), signaling that the Commission expects...
Suggested Considerations
- Review and obtain the updated submission instructions on the CFTC Portal and ensure legal, compliance, and operations staff understand the consolidated filing functionality and any new formatting or data‑entry requirements.
- Update internal product approval and submission procedures (including Part 40 playbooks and checklists) to reflect the ability to file a single set of documents for multiple closely related contracts, and to define when consolidation is appropriate.
- Revise internal documentation templates (e.g., product term sheets, legal analyses, core principle compliance memos, risk assessments) so that they can explicitly support multiple closely related contracts in a single package where relevant.
- Adjust governance workflows (approvals, sign‑offs, and quality checks) so that:
- Each contract included in a consolidated submission is clearly identified and traceable, and
Key Dates
– Executive Order 14243 is issued, setting an administrative objective to eliminate bureaucratic duplication and inefficiency, which this CFTC enhancement is designed to support
– CFTC announces and launches the Portal enhancement permitting consolidated product self‑certification submissions for multiple closely related contracts
Compliance Impact
Non‑compliance with the updated filing process is unlikely to result in direct enforcement, but incorrect or incomplete use of consolidated submissions could delay product listings, prompt CFTC information requests, or lead to questions regarding the adequacy and completeness of self‑certification packages. Over time, persistent deficiencies in product submissions could increase regulatory scrutiny of a venue’s compliance controls and governance around new product listings.
AI-generated analysis. May contain errors or omissions — verify with the
original CFTC source
before acting. Full disclaimer.
Broker DealerBankAsset Manager No description available.
The CFTC has issued a policy statement confirming that **perpetual contracts listed as futures on designated contract markets (DCMs) will be subject to case‑by‑case review under CFTC Regulation 40.3**, rather than being treated as a standard product class. The trigger is a contemporaneous CFTC order allowing a DCM to list a bitcoin spot‑referencing perpetual contract as a futures contract, while clarifying that perpetuals on other asset classes are not automatically covered and must be submitted for prior Commission review.
What Changed
- - The CFTC formally recognizes that perpetual contracts may be listed as “futures contracts” by DCMs, as evidenced by an order permitting listing of a perpetual contract referencing the spot price of...
- The Commission states that perpetual contracts have “unique characteristics” that vary by underlying asset, and therefore they will not be treated as a homogeneous product category for listing...
- For perpetual contracts referencing asset classes not covered by the contemporaneous bitcoin perpetual order, the Commission indicates that the appropriate path is a case‑by‑case review under CFTC...
- The policy statement signals that DCMs should expect closer CFTC scrutiny of perpetual contract design, including settlement mechanisms and underlying market integrity, before new perpetuals (beyond...
- The statement confirms that it is a policy statement rather than a binding rule, but it effectively sets Commission expectations for how DCMs must approach the listing of perpetual contracts going...
Suggested Considerations
- DCMs intending to list new perpetual contracts must route proposed products that are not clearly covered by the existing bitcoin perpetual order through a Commission Regulation 40.3 case‑by‑case review process, and should build internal product‑approval workflows accordingly.
- DCMs must enhance their surveillance, market‑integrity, and risk‑management frameworks for perpetual contracts, including monitoring of the referenced spot market, funding‑rate or cash‑flow mechanisms, and potential manipulation vectors stemming from the underlying asset.
- FCMs and clearing members should identify client exposure to perpetual futures, review margin models and risk limits, and ensure that risk disclosures, product descriptions, and account‑opening documentation accurately reflect the regulatory status and unique risks of perpetual futures.
- Compliance teams at DCMs and intermediaries should update policies and procedures for new product approval, explicitly flagging perpetual contracts as requiring heightened CFTC engagement and governance review before listing.
- Legal and regulatory affairs teams should brief senior management and boards on the policy statement, emphasizing that future perpetual contracts on non‑bitcoin or non‑covered asset classes carry additional regulatory scrutiny and potential delays due to the required case‑by‑case review.
Key Dates
– CFTC issues the policy statement on listing of perpetual contracts and an order permitting a DCM to list a perpetual futures contract referencing the spot price of bitcoin
– Policy statement is published in the Federal Register; from that point, DCMs and market participants can treat it as the Commission’s formal articulation of expectations for perpetual contract listings
Compliance Impact
Non‑compliance with the Commission’s articulated expectation to use Regulation 40.3 review for perpetual contracts outside the scope of the bitcoin perpetual order could lead to CFTC objections to product listings, enforcement actions, or mandated contract modifications or delistings. The impact is medium‑to‑high for DCMs and intermediaries involved in perpetual products, given the direct effect on product strategy, time‑to‑market, and potential litigation or supervisory risk if perpetuals are listed or operated inconsistently with the policy statement.
AI-generated analysis. May contain errors or omissions — verify with the
original CFTC source
before acting. Full disclaimer.
Crypto ExchangeBroker DealerHedge Fund Policy statement 15/26
PS15/26 sets out the PRA’s final Phase 1 reforms to **Pillar 2A capital methodologies and reporting**, aligned with the UK’s Basel 3.1 implementation and intended to modernise how risks beyond Pillar 1 are captured. It introduces revised approaches and expectations across credit, operational, pension obligation, market and counterparty credit risk, plus substantial updates to ICAAP/SREP guidance and Pillar 2 reporting for both mainstream firms and SDDTs.
What Changed
- - The PRA finalises amendments to the Reporting Pillar 2 Part of the PRA Rulebook, including updated Pillar 2 data items (FSA072–FSA076 and FSA081) and an updated Pillar 2 reporting schedule, with...
- The PRA issues an updated Statement of Policy (SoP) 5/15 – The PRA’s methodologies for setting Pillar 2 capital, providing revised methodologies across credit, operational, pension obligation, market...
- The PRA issues an updated SoP 5/25 – The PRA’s methodologies for setting Pillar 2 capital for Small Domestic Deposit Takers (SDDTs), tailoring Pillar 2A approaches and expectations for SDDTs.
- The PRA updates Supervisory Statement (SS) 31/15 – ICAAP and SREP, clarifying expectations on how firms should assess, document and justify Pillar 2A capital in ICAAPs, including how to reflect...
- The PRA updates SS 4/25 – ICAAP and SREP for SDDTs, setting proportionate ICAAP expectations and aligning SDDT guidance with the revised Pillar 2A framework.
Suggested Considerations
- Map your firm’s current Pillar 2A capital framework against the updated SoP 5/15 and, where applicable, SoP 5/25 to identify methodology changes across credit, operational, pension, market and counterparty credit risk.
- Update ICAAP methodologies, models and documentation to reflect revised PRA expectations, including new or enhanced use of credit risk and operational risk scenarios and any updated calibration standards.
- Review and, where necessary, redesign ICAAP governance (board oversight, senior management ownership, model risk and validation frameworks) to ensure that new scenario‑driven and systematic Pillar 2A methodologies are subject to appropriate challenge and approval.
- For firms with material sovereign, central bank, regional government or unconditionally cancellable retail exposures, implement the new systematic Pillar 2A credit risk methodologies and assess the impact on capital requirements and risk‑weighted exposure allocation.
- For firms with significant operational risk, enhance scenario analysis frameworks to capture low‑frequency, high‑severity loss events at the PRA’s expected soundness level, and embed these outputs into ICAAP capital quantification.
Key Dates
– PRA published CP12/25 launching Phase 1 of the Pillar 2A review and consulting on revised methodologies and reporting
– Consultation period for CP12/25 closed, with industry feedback informing PS15/26
– Changes relating to pension obligation risk and market/counterparty credit risk methodologies and associated reporting expectations take effect
– Basel 3.1 standards are implemented in the UK and the retirement of the refined Pillar 2A methodology takes effect; Phase 1 Pillar 2A changes for credit and operational risk are aligned to this Basel 3.1 implementation date
– PRA plans to publish a further consultation paper (Phase 2) on an in‑depth review of individual Pillar 2A methodologies
Compliance Impact
The impact is high: the reforms change how Pillar 2A capital is calculated, justified and reported, with direct consequences for total capital requirements, ICAAP content and supervisory dialogue. Failure to implement the new methodologies and reporting expectations on time can lead to higher capital add‑ons, adverse SREP outcomes, supervisory remediation programmes and potential restrictions on distributions or business growth.
AI-generated analysis. May contain errors or omissions — verify with the
original PRA source
before acting. Full disclaimer.
BankBroker Dealer
Policy statement 14/26
PRA Policy Statement PS14/26 finalises the restatement of CRR definitions into the PRA Rulebook Glossary, with consequential amendments across other Rulebook Parts and updates to SS15/13 on groups. For compliance teams, the key issue is transition planning: the remaining CRR definitions are being moved out of the CRR framework, and firms must ensure their policies, capital documentation, systems, and references align with the PRA Rulebook versions before the repeal of CRR Articles 4–5 takes effect on 1 January 2027.
What Changed
- - The PRA has finalised new and restated PRA Rulebook Glossary definitions that replace the CRR definitions previously found in Articles 4, 4A, 4B and 5 for PRA Rulebook purposes.
- The PRA has made consequential amendments across other Parts of the PRA Rulebook to align internal cross-references and terminology with the new glossary structure.
- The PRA has updated Supervisory Statement SS15/13 – Groups to reflect the transfer of CRR definitions into the PRA Rulebook framework.
- The PRA has stated that the vast majority of definitions are restated without substantive policy change, but some definitions were clarified for drafting consistency and readability.
- HM Treasury has set the legislative timetable so that the relevant CRR Articles 4–5 will be revoked from 1 January 2027, while the statutory restatement of selected definitions was made in April 2026.
Suggested Considerations
- Review all internal policies, manuals, and regulatory interpretation documents that currently cite CRR Articles 4, 4A, 4B, or 5 and replace those references with the corresponding PRA Rulebook Glossary definitions.
- Update capital adequacy, prudential reporting, and risk management systems to use the new PRA Rulebook terminology where definitions have moved from the CRR text.
- Reconcile group supervision materials, governance papers, and consolidation analyses against the revised SS15/13 wording to ensure group structures are assessed using the updated definitions.
- Map every affected business line and legal entity to determine which Rulebook Parts and counterparties rely on the transferred CRR definitions.
- Test template agreements, customer disclosures, and internal controls for terminology drift where contractual drafting depends on CRR-defined concepts.
Key Dates
- HM Treasury published its Policy Update on applying the FSMA model of regulation to the UK CRR and proposed revoking the remaining CRR provisions while restating only necessary definitions
- PRA published CP19/25 proposing the transfer of CRR definitions into the PRA Rulebook Glossary and consequential amendments across the Rulebook
- PRA published earlier final policy work on CRR restatement and related implementation measures, indicating the wider restatement programme was already underway
- HM Treasury published a policy update confirming it would proceed largely as consulted on, with a change to the statutory definition of “securitisation” for consistency with PRA Basel 3.1 rules
- The commencement statutory instrument revoking CRR Articles 4–5 was made, with effect from 1 January 2027
Compliance Impact
The compliance impact is moderate to high because this is a definitional restatement rather than a wholesale policy rewrite, but it affects the legal basis of many prudential references and could create misstatement risk if firms continue to rely on revoked CRR text after 1 January 2027. Non-compliance may lead to inaccurate capital, governance, or perimeter analysis, and could trigger supervisory findings where firms have not updated systems, documentation, or controls to the new Rulebook structure.
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original PRA source
before acting. Full disclaimer.
BankAsset ManagerBroker Dealer Policy statement 13/26
The PRA’s Policy Statement PS13/26 finalises the CP20/25 proposals on UK branches of third‑country (re)insurers, including raising the subsidiarisation threshold, embedding existing reporting and investment waivers into the Rulebook, and updating supervisory expectations on ORSA and resolution. Compliance teams at third‑country branches must now recalibrate threshold monitoring, overhaul reporting processes, and update governance and documentation to align with the revised Third Country Branches and Reporting Parts of the PRA Rulebook, updated SSs, and new Statements of Policy.
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What Changed
- - The PRA confirms an increase in the third‑country branch subsidiarisation threshold for liabilities covered by the Financial Services Compensation Scheme (FSCS) from £500 million to £600 million,...
- Third‑country branch undertakings are now explicitly required to notify the PRA where projections show their FSCS‑covered liabilities may exceed the £600 million subsidiarisation threshold within a...
- The PRA embeds in the Rulebook new quantitative thresholds for regulatory reporting, replacing the existing modification by consent (MbC) under Solvency II Reporting 2.2(1) for third‑country...
- Under the new regime, only branches (excluding pure reinsurance branches) with at least £1 billion gross written premiums or £2 billion in branch provisions (based on the prior year’s annual...
- The PRA discontinues quarterly reporting for certain non‑life claims templates and reinstates two annual reporting templates (IR.19.01.01 – non‑life insurance claims and IR.20.01.01 – development of...
Suggested Considerations
- Assess current and projected FSCS‑covered UK branch liabilities against the new £600 million subsidiarisation threshold and implement or update a robust three‑year forecasting process to identify potential threshold breaches.
- Update internal PRA notification procedures and early‑warning triggers so that the branch informs the PRA promptly if forecasts show FSCS‑covered liabilities could exceed the £600 million threshold within three years.
- For branches approaching or exceeding the new threshold, initiate or refresh internal structural options analysis (branch vs subsidiary), including timeline, capital, governance, and operational impacts, and prepare for early engagement with the PRA on subsidiarisation expectations.
- Map gross written premiums and branch provisions against the new £1 billion GWP and £2 billion provisions reporting thresholds and determine whether the branch will be subject to the full or reduced suite of third‑country branch regulatory reporting templates from 31 December 2026.
- Redesign regulatory reporting processes, systems, and controls to align with the new reporting perimeter, including identifying which templates will be required, adjusting data capture, and ensuring capacity to produce reinstated templates IR.19.01.01 and IR.20.01.01 on an annual basis.
Key Dates
– PRA publishes CP20/25, proposing changes to third‑country branch policy, including the higher subsidiarisation threshold and new reporting thresholds
– Consultation period for CP20/25 closes; representations received from affected firms and stakeholders
– PRA indicates that the increase in subsidiarisation threshold from £500 million to £600 million would take effect on publication of the relevant policy statement (PS13/26), with immediate relevance for threshold monitoring and branch vs subsidiary planning
– Rulebook and policy changes (including amendments to the Third Country Branches and Reporting Parts, reinstatement of annual templates IR.19.01.01 and IR.20.01.01, embedded reporting thresholds, embedded pure reinsurance relief, updates to SS44/15, SS41/15, SS19/16, SoP6/24, SoP7/24, and SoP1/19, and disapplication/restatement of EIOPA Branch Guidelines) are scheduled to come into force
Compliance Impact
The impact is material for all UK branches of third‑country (re)insurers, particularly those near the new subsidiarisation and reporting thresholds, with consequences including potential forced subsidiarisation, expanded reporting burdens, or supervisory challenge if expectations on forecasting, ORSA, or resolution planning are not met. Non‑compliance could trigger PRA supervisory interventions, restrictions on business, and increased scrutiny during authorisation and ongoing supervision.
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InsuranceBank
The Treasury has published its policy statement today on reform of the Consumer Credit Act 1974 (CCA). Reform of the CCA is an important step towards a more flexible regime that supports effective competition and innovation, while maintaining appropriate consumer protection both now and in the future. The proposals set out a framework that places greater emphasis on FCA rules and guidance rather than prescriptive requirements set out in legislation.We intend to consult on the key elements of ...
HM Treasury has issued a policy statement on reform of the Consumer Credit Act 1974 (CCA), signalling a strategic shift from prescriptive, statute-based requirements towards an FCA rulebook-led regime for consumer credit. The FCA’s response confirms it will consult on moving key CCA elements into FCA rules and guidance, anchored in the Consumer Duty, which will materially reshape documentation, processes and conduct standards across the consumer credit lifecycle.
What Changed
- - The UK Government has confirmed a programme to reform the Consumer Credit Act 1974, moving away from detailed prescriptive legislative requirements towards a more flexible framework based on FCA...
- The FCA has stated its intention to consult on “key elements” of the consumer credit framework that are currently in primary or secondary legislation, where it has the power to do so, covering the...
- The Consumer Duty (Principle 12, PRIN 2A) is explicitly confirmed as the overarching framework for the future consumer credit regime, meaning consumer credit firms will be expected to demonstrate...
- The FCA has signalled that existing consumer rights and protections under the CCA (including cancellation and withdrawal rights, termination, and early settlement rights) will be reviewed and...
- Any new FCA rules arising from CCA reform will be supported by a formal cost–benefit analysis and shaped through stakeholder engagement, implying a structured consultation process (likely one or more...
Suggested Considerations
- Establish an internal CCA reform working group (legal, compliance, product, operations) to track HM Treasury and FCA publications on Consumer Credit Act reform and prepare coordinated responses.
- Map all existing product lines and customer journeys against current CCA and CONC requirements to identify areas most likely to be affected if obligations move from legislation into FCA rules (e.g. pre‑contract disclosure, notices of sums in arrears, default notices, early settlement calculations).
- Review your Consumer Duty implementation for consumer credit products (especially outcomes testing, fair value assessments and customer support processes) to ensure it can absorb additional or re‑framed requirements that may migrate from the CCA into the FCA Handbook.
- Compile an inventory of CCA‑dependent documentation (agreements, pre‑contract information, statutory notices, arrears and default letters, early settlement communications) and assess the effort required to update them if the form or content requirements are recast in FCA rules.
- Enhance regulatory horizon‑scanning processes to include systematic monitoring of HM Treasury CCA reform material and FCA consultations, ensuring early awareness of consultation questions and proposed Handbook text.
Key Dates
– HM Treasury’s policy statement has been published, but no specific implementation dates for CCA reform or FCA rule changes are given in the FCA response
– FCA consultation(s) on key elements of the consumer credit framework are announced as forthcoming; exact dates are not yet specified
– Future milestones such as FCA Policy Statements, Handbook changes and statutory amendments will follow, but no indicative timetable is provided in the FCA response
Compliance Impact
Non‑compliance with the eventual FCA rules replacing or supplementing CCA provisions will expose firms to supervisory intervention, enforcement action, consumer redress and potentially large remediation exercises under the Consumer Duty. Given the centrality of consumer credit to many business models and the likely breadth of changes, firms that do not prepare early may face significant operational, conduct and litigation risk.
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
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Policy statement 12/26
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